PRIVACY POLICY

EFFECTIVE DATE: NOVEMBER 12, 2014

PURPOSE OF POLICY

StudyPug Inc. and StudyPug (HK) Ltd. ("Company" or "we" or "us" or "StudyPug") is committed to respecting the privacy rights of its customers, visitors, and other users of our website www.StudyPug.com (the "Website") and services offered through the Website (the "Services"). We created this Privacy Policy (this "Policy") to give you confidence as you visit the Website and use the Services, and to demonstrate our commitment to fair information practices and the protection of privacy. This Policy is only applicable to the Website, and not to any other websites that you may be able to access from the Website, each of which may have data collection and use practices and policies that differ materially from this Policy.

INFORMATION COLLECTION PRACTICES

Types of Information Collected:

Traffic Data. We automatically track and collect the following categories of information when you visit our Website: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Website; and (4) types of web browsers used to access the Website (collectively "Traffic Data"). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Website. We also use "cookies" to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly, and to store your password so you do not have to re-enter it each time you visit the Website. Any cookies we place will automatically expire after a set period.

Personal Information. In order for you to access certain Services that we offer via the Website, we require you to provide us with certain information that personally identifies you ("Personal Information"). Personal Information includes the following categories of information: (1) "Contact Data" (such as your name, mailing address, and e-mail address); (2) "Financial Data" (such as your account or credit card number); and (3) "Demographic Data" (such as your postal code). If you communicate with us by e-mail, like us on Facebook, post messages to any of our social media, or complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information.

USE OF INFORMATION COLLECTED PRACTICES

Uses of Information:

Our use of your Personal Information. We use Contact Data to send you information about our company or our products or services, or promotional material from some of our partners, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain Services and to charge you for such Services. We use your Demographic Data to customize and tailor your experience on the Website, displaying content that we think you might be interested in and according to your preferences.

Sharing of Personal Information. We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally- identifiable) basis. We share Contact Data with other companies who may want to send you information about their products or services. We also share Contact Data and Financial Data with our business vendors who assist us by performing core services (such as Website serving/hosting, billing, fulfillment, or data storage and security) related to our operation of the Website. We are not responsible for the privacy practices of such other business vendors. We maintain a procedure for you to review and request changes to your Personal Information; this procedure is described below.

User Choice Regarding Collection, Use, And Distribution of Personal Information. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Website but you will not be able to access and use those Services or portions of the Website that require your Personal Information.

CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service ("TOS"). Your Personal Information is stored on secure servers that are not accessible by third parties. Note that these servers are in the United States of America and, as such, your Personal Information is subject to the laws of that country. Where applicable, our Website supports standard Internet encryption abilities with compatible browsers.

User Ability to Access, Update and Correct Personal Information. If you want to access, correct or update your Personal Information, please email us at privacynotification@studypug.com or click on the "Account" link at the top of this webpage.

Lost or Stolen Information. You must promptly notify us if your credit card, user name, or password is lost, stolen, or used without permission. In such event, please email us at privacynotification@studypug.com, and we will remove that credit card number, user name, or password from your account and update our records accordingly.

Public Information. The Website contains links to or from other websites or service providers, as well as content from other websites or service providers (e.g. Facebook, Twitter, Google). We are not responsible for the privacy practices or content of such websites or service providers or any content they place on our Website. Please understand that any information that is disclosed to those websites, or disclosed as User Generated Content becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information on public websites or post it as User Generated Content.

CHANGE OF CONTROL

Traffic Data and Personal Information will be transferred in the event of a Change of Control of Company. "Change of Control" means (a) a sale to a third party of all or substantially all of the assets of a party; or (b) the transfer to a third party of fifty percent (50%) or more of the outstanding voting power of such party.

DISPUTE RESOLUTION

You will not bring, nor combine with any others to bring, a class action against StudyPug for any claim arising under the TOS, the Website, the Services or any other reasons. All claims brought against StudyPug for any relief except injunctive or other equitable relief shall be addressed in binding non-appearance-based arbitration. In such a situation, you will comply with the following rules: (a) the arbitration shall be conducted by telephone, online, or based solely on written submissions; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; and (c) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Website and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Website.